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`EXHIBIT 1
`Philips v. Fitbit
`Proposed Alternative Schedule
`Fitbit emphasizes that it does not believe further dates should entered in the schedule, and that
`the Court should extend the stay for at least 60 more days due to the COVID-19 virus pandemic.
`Philips reiterates that there is no need to further extend a stay.
`
`Description
`
`Exchange of Claim terms per
`L.R. 16.6(e)(1)(A)
`
`Deadline to Meet and Confer
`per 16.6(e)(1)(B)
`
`Filing of Joint Claim
`Construction Statement per
`L.R. 16.6(e)(1)(D)
`
`Opening Claim Construction
`Briefs per L.R. 16.6(e)(2)
`
`Deadline for Deposition of
`Claim Construction Experts
`per L.R. 16.6(e)(3)
`
`Deadline for Responsive
`Claim Construction Briefs pet
`L.R. 16.6(e)(4)
`
`Claim Construction Hearing
`
`Deadline to Serve Written
`Fact Discovery.
`
`Plaintiff’s Proposed
`Dates
`
`Defendant’s Proposed Dates in
`the alternative to extending the
`current discovery stay
`
`Apr. 9, 2020
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`Sept. 17, 2020
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`Apr. 16, 2020
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`Sept. 24, 2020
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`Apr. 23, 2020
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`Oct. 1, 2020
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`May 7, 2020
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`Oct. 22, 2020
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`May 28, 2020
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`Nov. 12, 2020
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`June 18, 2020
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`Dec. 3, 2020
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`July 8, 2020
`(or at Court’s
`convenience)
`
`Aug. 12, 2020
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`Feb. 2, 2021
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`Mar. 19, 2021
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`Fact Discovery Cutoff
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`Sept. 23, 2020
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` Apr. 23, 2021
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`Opening Expert Reports
`
`Oct. 28, 2020
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`May 7, 2021
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`1
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`Case 1:19-cv-11586-IT Document 47-1 Filed 03/20/20 Page 2 of 2
`
`Description
`
`Plaintiff’s Proposed
`Dates
`
`Defendant’s Proposed Dates in
`the alternative to extending the
`current discovery stay
`
`Responsive Expert Reports
`
`Dec. 16, 2021
`
`Expert Depositions
`Completed
`
`Dispositive Motions
`
`Pre-Trial Conference
`
`Jan. 28, 2021
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`Feb. 26, 2021
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`June 4, 2021
`(or at Court’s
`convenience)
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`June 18, 2021
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`July 9, 2021
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`Aug. 6, 2021
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`Nov. 12, 2021
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`2
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